Lead and Copper Rule

In 1991, the Environmental Protection Agency (EPA) published the Lead and Copper Rule to minimize lead and copper in drinking water. The rule replaced the previous standard of 50 ppb, measured at the entry point to the distribution system. The rule established a maximum contaminant level goal of zero for lead in drinking water and an action level (AL) of 0.015 milligrams per liter (mg/L) for lead and 1.3 mg/L for copper based on 90th percentile level of tap water samples. An action level exceedance is not a violation but triggers other requirements to minimize exposure to lead and copper in drinking water that include water quality parameter monitoring, corrosion control treatment, source water monitoring/treatment, public education, and lead service line replacement. Lead and Copper Rule requirements apply to all Community and Non Transient Non Community Public Water Systems. In 2000, EPA published revisions to the Lead and Copper Rule to address implementation problems and issues arising from legal challenges to the 1991 rule. The revisions also streamlined and reduced monitoring and reporting burdens. In 2004, EPA published minor corrections to the Lead and Copper Rule to reinstate text that was inadvertently dropped from the rule during previous revisions. EPA then published proposed revisions to the Lead and Copper Rule in 2006. In October 2007, the EPA finalized seven targeted regulatory changes to the National Primary Drinking Water Regulations for lead and copper. This final rule strengthens the implementation of the Lead and Copper Rule in the following areas: monitoring, treatment processes, public education, customer awareness, and lead service line replacement. These changes provide more effective protection of public health by reducing exposure to lead in drinking water.

The following documents and links are provided to help water system owners and operators understand their Lead and Copper Rule responsibilities:

 
Lead and Copper Rule Revisions

Use the following template to record the service line material inventory

Please submit the LCRR service line material inventory to DPH.LeadandCopper@ct.gov. For files that are too large to send via email, please let us know at DPH.LeadandCopper@ct.gov, we will set up a OneDrive folder for you to upload your inventories.

Notification of Known or Potential Service Line Containing Lead (40 CFR § 141.85(e))

Training Recording

Comments for Proposed Long-Term Revisions of the Lead and Copper Rule (LCR): 

Correspondence

Lead Action Level Exceedance Public Notification

Beginning October 16, 2024, the Lead and Copper Rule Revisions (LCRR) requires Community (CWS) and Non-Transient Non-Community Public Water Systems (NTNC) that exceed the 90th percentile lead action level based on tap water samples to issue a Tier 1 Public Notification (PN) no later than 24 hours after the CWS or NTNC learns of the lead action level exceedance (ALE). In addition, within 24 hours after learning the lead ALE, a copy of the PN must be sent to CT DPH and to the EPA at DPH.PNCoordinator@ct.gov and LeadALE@epa.gov. The following documents have been developed to assist public water systems in developing the public notification that meet the content and delivery requirements:

The CWS and NTNC must submit to CT DPH a completed and signed certification of compliance within 10 days after issuing the Tier 1 PN at DPH.PNCoordinator@ct.gov.

Consumer Notice Requirements

All systems shall provide a notice of the individual tap results from lead tap water monitoring to the occupants of the residence/location where the tap was tested. The notice must be delivered to consumers within 30 days of the sample results being received from the laboratory even if the results did not exceed the action level for lead. The following templates may be used to satisfy the Consumer Notification Requirements:

No later than three months following the end of the monitoring period, systems shall mail a completed and signed Certification of Consumer Notification of Lead Tap Water Sampling with a sample copy of the Consumer Notice of tap results to the Department.

Lead Public Education

Community (CWS) and Non-Transient Non-Community Public Water Systems (NTNC) that exceed the lead action level based on tap water samples are required to deliver lead public education materials to customers within sixty (60) days after the end of the monitoring period in which the exceedance occurs. The following documents have been developed to assist public water systems in developing public education materials that meet the content and delivery requirements:

No later than nine (9) days after the end of the period in which the exceedance occurs, systems shall submit a completed and signed Certification of Lead Public Education Content and Delivery and a copy of the Lead Education Materials delivered to the Department.

Once a PWS exceeds the lead action level, there is a series of steps required to be conducted by the water system, which is monitored and enforced by DPH.  Some of the steps include providing public education to the system’s consumers, proposal of a corrosion control plan and follow up testing for lead at a monitoring frequency of every six month (Jan 1st to June 30th and July 1st to Dec 31st of each year).   DPH will update the above list at the end of each monitoring period.  For more information or the latest lead test results, please contact the public water system directly.

For more information on the Lead and Copper Rule, please refer to the flowchart

Water Infrastructure Improvements for the Nation (WIIN) Act Notification 

The WIIN Act, enacted on December 16, 2016, modified Section 1414 of the Safe Drinking Water Act to include public notification requirements for exceedances of the lead action level under the Lead and Copper Rule. As a result, the Community {CWS) or Non-Transient Non-Community {NTNC) public water system is required to provide public notice as soon as practical, but not later than 24 hours, after the CWS or NTNC learns of the lead action level exceedance.

Copper Action Level Exceedance Notification

A CWS or NTNC that exceeds the copper action level based on tap water samples shall notify consumers of the concentration by direct mail, not later than 30 calendar days after the CWS or NTNC learns of the exceedance. The following documents have been developed to assist public water systems in developing public notification materials that meet the content and delivery requirements:

 

Lead and Copper Rule Improvements

The Lead and Copper Rule Improvements (LCRI) is a federal safe drinking water rule that the United States Environmental Protection Agency (EPA) promulgated in the Code of Federal Regulations (CFR) on October 30, 2024. The LCRI strengthens requirements to protect children and adults from lead in drinking water. The LCRI has an effective date of December 30, 2024 and a compliance date of November 1, 2027.

Key Provisions of the LCRI:

  1. Mandates lead service line replacements. Water systems must replace lead service lines within 10 years.
  2. Requires locating existing lead pipes. Water systems must regularly update their service line material inventories and develop replacement plans that prioritize vulnerable and disproportionately affected communities.
  3. Strengthens tap sampling requirements. Water systems must collect both first-liter and fifth-liter samples from sites with lead service lines, using the higher result for the 90th percentile calculation.
  4. Lowers the lead action level from 15 ppb to 10 ppb, requiring earlier intervention.
  5. Additional requirements to reduce exposure to lead in drinking water. Water systems with multiple exceedances of the lead action level must continue optimizing corrosion control treatment, conduct additional community outreach, and make filters that are certified to reduce lead available to all consumers.
  6. Communicating transparently and frequently. More frequent and proactive communications about lead pipes and replacement plans. The Consumer Confidence Reports (CCR) must include clear health language about the dangers of lead, information about testing for lead in schools and childcare facilities, and information about service line material and replacement plans.

The final LCRI requires the following to be submitted to CT DPH. Please submit to CT DPH at DPH.LeadandCopper@ct.gov.

By November 1, 2027:

By January 1, 2028

✔Baseline Service Line Inventory

✔Sampling Site Plan

✔Service Line Replacement Plan

✔Tap Sampling Protocol

✔List of School and Childcare Facilities that are customers of the system

 

✔Inventory Validation Waiver Request

 

The Drinking Water Section will be providing additional information and forms to help water systems comply with these reporting requirements once the materials are developed.

Source of Lead in Drinking Water:

In drinking water, the primary source of lead is from pipes, which can present a risk to the health of children and adults.

Health Effects of Lead:

There is no safe level of lead in drinking water. Exposure to lead in drinking water can cause serious health effects in all age groups, especially pregnant people, infants (both formula-fed and breastfed), and young children. Some of the health effects to infants and children include decreases in IQ and attention span. Lead exposure can also result in new or worsened learning and behavior problems. The children of persons who are exposed to lead before or during pregnancy may be at increased risk of these harmful health effects. Adults have increased risks of heart disease, high blood pressure, kidney or nervous system problems. Contact your health care provider for more information about your risks.

Information and Resources:

For more information on the LCRI, please visit the following EPA links:

Lead and Copper Rule Improvements | US EPA

Frequently Asked Questions on the LCRI | US EPA

Lead and Copper Rules Comparison Guide | US EPA

EPA Technical Fact Sheets and Other Supporting Materials | US EPA

Information related to lead service line | US EPA

Funding Resources for lead service line replacement | US EPA

Water Technical Assistance (WaterTA) | US EPAGet the Lead Out Initiative | US EPA

Protect Your Tap: A Quick Check for Lead | US EPA